Mr. Mike Ryan
San Luis Obispo County Board of Supervisors
Room 370, County Government Center
San Luis Obispo, California 93408
RE: Flight Restrictions over Diablo Canyon Nuclear Storage Facility
Dear Mr. Ryan:
The Aircraft Owners and Pilots Association (AOPA), representing over 400,000 general aviation pilots and aircraft owners nationwide, objects to a recent county recommendation to impose a 2-mile wide, 2,000-foot high flight restriction over the proposed dry storage facility in Diablo Canyon. The restriction is unwarranted because general aviation aircraft do not pose any threat to the proposed facility. The restrictions would unnecessarily impact air commerce in the area. There are more than 49,859 pilots flying 23,454 general aviation aircraft based in the state of California.
It is important to note that independent nuclear engineers have concluded that general aviation aircraft are not effective weapons and are not a significant threat to nuclear power plants or to storage facility safety. With concern to the dry cask storage method, spent fuel is stored in massive shielding systems built out of stainless steel and/or steel-reinforced concrete. The weight of this type of storage container ranges from 200,000 lbs to 300,000 lbs when loaded with spent fuel rods. The typical general aviation aircraft usually constructed from light aluminum or composite materials weighs slightly over 2,000 lbs (less than a Honda Civic).
In a December 2002 study commissioned by the Nuclear Energy Institute (NEI), they found that a large commercial airliner striking a dry cask container loaded with spent fuel would not release radionuclides to the environment. In fact, the study found that a steel container would only be dented and a steel/concrete structure would have cracking and crushing limited to the area of impact. Again, no radiation was released.
In a June 2002 Senate hearing, Senator Christopher (Kit) Bond (R-Mo.) stated, "Commercial nuclear plants are probably the most physically secure and least vulnerable of our nation's industrial infrastructure. They are robust, hardened facilities with numerous redundant systems designed to assure public safety."
Homeland Security Secretary Tom Ridge, in consultation with top security advisors, has reviewed safety concerns on several occasions and has determined that airspace restrictions over nuclear power plants are not necessary.
In addition, the federal government has already taken action to ensure that general aviation pilots stay away from nuclear power plants and other sensitive facilities. The Federal Aviation Administration (FAA) issued an advisory to pilots to avoid circling or loitering over power plants. AOPA supports this advisory and encourages pilots to fly responsibly.
Since the attacks of September 11, 2001, President Bush has continued to be firm in his desire that the U.S. should not allow terrorist attacks to undermine our way of life. Arbitrary airspace restrictions are contrary to the President's message. It is inappropriate for the federal government to institute airspace restrictions or allow the closing of vital general aviation airspace and airports in proximity to them.
If the FAA or the Transportation Security Administration (TSA) were to identify credible threats to nuclear power plants and storage facilities, rest assured that the appropriate federal agencies would take action to protect its citizens.
Senior Vice President
Government and Technical Affairs
October 16, 2003